The Mayor of London’s Ultra Low Emission Zone proposals lack ambition. The zone should be made bigger, stronger, and more effective.

The consultation on the Mayor of London’s plan to improve our city’s air quality by making central London an Ultra Low Emission Zone (ULEZ) ends today (if you haven’t submitted a response please do so here, it only takes a few minutes).

The Mayor’s proposals would require all motor vehicles driven within the ULEZ, which would cover the same area as the congestion charge zone, to meet new exhaust emissions standards with the aim of limiting nitrogen dioxide (NO2) emissions. The ULEZ would take effect from 7 September 2020 and would apply 24 hours a day, 7 days a week.

Private vehicles whose emissions don’t meet the standards proposed (the 2006-standard Euro-4 for petrol vehicles and the latest Euro-6 for diesel vehicles) would have to pay a daily charge. Non-compliant lorries and coaches would have to pay £100 a day and cars, vans, minibuses, mopeds and motorcycles £12.50. This charge would be levied on top of the daily congestion charge, meaning below standard HGVs and coaches would have to pay over £120 a day to drive through central London and cars £24 (more if the congestion charge rises before 2020). In addition, all taxis and private hire vehicles presented for licensing from 1 January 2018 would need to be zero emission capable.

The Mayor’s ULEZ proposals are to be welcomed. Despite reductions in the concentration of a number of airborne pollutants over recent decades, levels of PM10, NO2 and NOx across London, including parts of our Borough such as the Woolwich Road flyover, are still unacceptably high. Urgent action is needed not only to reduce the staggering number of premature deaths that result from our city’s noxious air (analysis released last year by Simon Birkett of Clean Air London estimates that the number of deaths attributable to NO2 and particulate matter PM2.5 air pollution in London may be higher than previously estimated at around 7,500 deaths each year) but also to ensure that London meets EU air quality targets for NO2 and so avoids European Union infraction proceedings. Of course not all London’s air quality problems come from motor vehicles but toxic exhaust fumes are its single biggest cause and a ULEZ is therefore a necessary first step to improving London’s poor air quality.

However, the Mayor’s proposals suffer from a distinct lack of ambition. First, they will not do nearly enough to expedite a rapid shift towards ultra low and zero emission capable vehicles. The scheme’s proposed uniform charging structure and the absence of a scrappage scheme that would incentivise and support owners of cars that do not meet ULEZ standards to upgrade will limit the extent to which the zone will accelerate the phase out of the most polluting vehicles, including those with diesel engines. Similarly, as the Society of Motor Manufacturers and Traders (SMMT) made clear in an open letter to the Mayor in December, the proposed emissions standards fall short of what would be required to promote the best available technologies across all vehicle classes. Under the proposals, 2006-standard Euro 4 petrol vehicles will be able to enter the ULEZ without charge meaning that, for example, petrol vehicles of up to 14 years of age – which emit CO2 emissions some 72% higher than the European fleet average – will still pass through central London after 2020 without penalty despite Euro 6 petrol and diesel vehicles being mandatory from next year. TfL does indicate in its timescales the possibility of strengthening the scheme in 2025 but if an upgrade is on the cards just five years after the scheme commences TfL should start to give the public, taxi operators and commercial vehicle operators a sense of what its stronger requirements might be now so that they can make informed decisions and potentially purchase a vehicle that will meet the strengthened 2025 standards, as well as the 2020 standards.

Secondly, the proposed zone boundary is unduly restrictive. Air quality in central London is undoubtedly poor but this silent killer is not a problem that’s exclusive to central London. Indeed, parts of inner London outside the proposed ULEZ boundaries also exceed the legal limit for NO2 concentrations. A ULEZ confined to the existing congestion charge zone risks incentivising additional car journeys through areas contiguous with it. Indeed, given that the proposed daily charges would be levied on top of the existing congestion charge there would be every incentive for polluting vehicles to divert around the ULEZ, resulting in potentially worse air quality around the zone’s fringes.

Thirdly, the proposals include a host of exemptions and variations that limit the zone’s impact and will undoubtedly give rise to accusations of double standards. For example, while all buses operating within the ULEZ will need to either meet Euro 6 and be hybrid (double decker) or zero emission (single decker) the Mayor’s 300 New Routemaster buses will escape charging or modification.

The proposals warrant a rethink. If the Mayor is serious about tackling London’s appalling air quality record then, falling short of upgrading the current Low Emission Zone to a ULEZ (the infrastructure is already in place for administration and enforcement and such a move would have benefits across the capital), he should have TfL explore the following as part of a revised ULEZ:

Including a mechanism by which standards can be incrementally tightened over time.

Developing a progressive charging structure, including higher levies against more polluting motors, in order to gradually phase out the worst polluting vehicles.

Introducing a scrappage scheme in tandem with the roll-out of the zone to support owners of cars that do not meet ULEZ standards to upgrade by ensuring they get a good price for their vehicles. The scheme could be financed (alongside other measures to improve air quality standards in London such as investment in electric buses and electric charging points) from any surplus from the ULEZ daily charges.

Setting out a clear framework for expanding the zone boundaries over time by allowing Boroughs with boundaries contiguous to the ULEZ (or contiguous with a progressively expanding ULEZ) to opt-in to the scheme and setting aside funds to ensure that those Boroughs that chose to opt into the zone do not suffer from the financial burden of introducing a scheme.

As things stand the proposals fall far short of the Mayor’s original promise of a ULEZ scheme that would “aim to ensure all vehicles driving in the centre of the capital during working hours would be zero or low emission”. A bigger, stronger, and more effective ULEZ could set a precedent for other cities, not just in the UK but around the world – many of which face similar air quality challenges – while at the same time boosting the low emission vehicle industry and accelerating the design and production of compliant vehicles. Given the growing body of scientific evidence attesting to the negative health impact of air pollution, particularly on the most vulnerable in our society such as children, older people and those with heart and respiratory conditions, and the disproportionately high impact of poor air quality on those living in deprived areas, we must seize the chance.